February 19, 2020
I'm a retail investor who has made use of various inverse and/or leveraged ETFs to better hedge and protect the portfolio I manage for several years now. These instruments are absolutely critical to my ability to meet the risk-adjusted returns I'm aiming for.
I strongly object to the proposal that some third party be empowered to evaluate and possibly deny my ability to understand and use these products. I'm an adult in full possession of my mental faculties. That should be enough for the government to know.
I understand that some naive investors have lost substantial amounts of money through the sort of ETFs in question. I'm pretty sure that such investors did not exercise due caution and ignored all warnings regarding these products that they encountered. Adults must have the freedom to commit follies. If the SEC wants to do something about this particular sort of folly, by all means mandate warnings that can't be missed. But don't take away my ability to properly hedge my portfolio, or make this ability subject to some corporate bureaucrat's approval.
Rule #S7-24-15 is a gross example of nanny state activism. Please don't do this.